As a complement to our previous regulatory updates, we are sharing crucial details regarding the upcoming EU Empowering Consumers for the Green Transition (ECGT) Directive (Directive (EU) 2024/825), which officially takes effect across Europe on September 27, 2026.
This directive significantly tightens the rules around green claims and sustainability labels in business-to-consumer communications. If you are an ETKO certified partner holding a ETKO COSMOS certification, here is exactly how this law impacts your operations and how your certification protects you.
1. The ETKO COSMOS Label Qualifies Under the New Rules
The new EU Directive strictly bans sustainability labels unless they are established by a public authority or built upon a qualifying certification scheme. Based on current legal assessments, the ETKO COSMOS scheme fully meets these rigorous requirements through its structured framework:
Publicly Available Rules: The COSMOS standard and all Certification Body (CB) details are transparently published on cosmos-standard.org.
Open & Equal Access: Any cosmetics company globally can apply under the exact same conditions.
Stakeholder-Driven Development: Standards are regularly revised through structured consultations involving brands, scientists, CBs, and industry bodies.
Enforced Non-Compliance Procedures: Non-conformities trigger corrective actions, suspension, or immediate certificate withdrawal. The mark cannot legally be used without a valid certificate.
Independent Third-Party Auditing: COSMOS-standard AISBL does not issue certificates itself. All audits are strictly conducted by separate, ISO 17065-accredited Certification Bodies like ETKO.
Key Takeaway: The ETKO COSMOS mark can continue to be displayed after September 27, 2026. Provided your certificate remains current and your Certification Body remains accredited, you are compliant—no relabeling is required on this basis alone.
2. Why ETKO COSMOS Protects Your Brand
Choosing ETKO COSMOS provides a legally robust and verifiable route to communicate your product's environmental and natural credentials. It significantly reduces your legal and reputational risks through four verifiable pillars:
Defined Scope: Certification applies strictly to clearly identified products and categories, removing ambiguity.
Specific Criteria: All documented requirements are freely accessible to consumers and retailers.
Controlled Claims: Logo use and claim wordings follow defined rules to prevent overstatement.
Auditable Evidence: Compliance is verified via on-site audits and documentation by independent, accredited CBs.
3. Critical Action Items: Reviewing Broader Environmental Language
While your ETKO COSMOS mark is secure, the Directive introduces separate obligations regarding the rest of your packaging and marketing copy that you must manage directly:
Generic Green Claims are Banned: Terms such as "eco-friendly", "green", "natural", "ecological", "biodegradable", or "sustainable" are banned as generic claims unless your product holds an EU Ecolabel or a nationally recognized ISO 14024 Type I ecolabel. The COSMOS mark alone does not justify these generic terms.
Scope Matching: If your certification only covers a specific aspect (e.g., the formula), you cannot make broad green claims about the entire product. Be highly precise.
Carbon Neutrality Bans: Claims of being "carbon neutral" that rely on carbon offsetting schemes outside your own production chain are now strictly prohibited.
Future Sustainability Promises: Future targets (e.g., "Carbon Neutral by 2030") require a detailed, publicly available, and independently verified plan with specific targets.
What to Do Before September 2026:
Audit Packaging & Marketing: Review all text for environmental language that extends beyond your explicit certification scope.
Evaluate Other Marks: Verify that any other trust marks displayed on your products stem from a qualifying certification scheme or public authority.
Maintain Certification: Keep your ETKO COSMOS certificate current and stay on schedule with us.
For guidance, reach out to ETKO to ensure your product claims remain fully compliant before the deadline!